Digital Envoy Inc., v. Google Inc., Doc.

119
Case 5:04-cv-01497-RS Document 119 Filed 03/16/2005 Page 1 of 2

1 DAVID H. KRAMER, State Bar No. 168452 (dkramer@wsgr.com)

STEPHEN C. HOLMES, State Bar No. 200727 (sholmes@wsgr.com)
2 WILSON SONSINI GOODRICH & ROSATI
Professional Corporation
3
650 Page Mill Road
4 Palo Alto, CA 94304-1050
Telephone: (650) 493-9300
5 Facsimile: (650) 565-5100
6 Attorneys for Defendant/Counterclaimant
Google Inc.
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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DIGITAL ENVOY, INC., ) CASE NO.: C 04 01497 RS
13 )
Plaintiff/Counterdefendant, ) DEFENDANT AND
14 ) COUNTERCLAIMANT GOOGLE
) INC.’S MISCELLANEOUS
15 v. ) ADMINISTRATIVE REQUEST TO
) FILE DOCUMENTS UNDER SEAL
16 GOOGLE INC., ) PURSUANT TO LOCAL RULE 79-5
)
17 Defendant/Counterclaimant. ) Judge: Hon. Richard Seeborg
) Courtroom: 4, 5th Floor
18 )
) Date: March 30, 2005
19 ) Time: 9:30 a.m.

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MISCELLANEOUS ADMINISTRATIVE REQUEST
TO FILE DOCUMENTS UNDER SEAL
CASE NO.: C04-01497 RS C:\NrPortbl\PALIB1\DAG\2618471_1.DOC

Dockets.Justia.com
 Case 5:04-cv-01497-RS Document 119 Filed 03/16/2005 Page 2 of 2

1 Defendant and counterclaimant Google Inc. (“Google”) hereby requests that the Court

2 permit it to file under seal the confidential version of Google Inc.’ Reply in Support of Its

3 Motion for Summary Judgment, and Exhibits P, Q, R and S to the Supplemental Declaration of

4 David H. Kramer in Support of Google Inc.’s Motion for Summary Judgment (“Supplemental

5 Kramer Declaration”).

6 Exhibit M to the Declaration of David H. Kramer is a document produced in this

7 litigation by Digital Envoy and is quoted in Google’s Reply memorandum. A public

8 memorandum with the designated material redacted is also being filed.

9 Plaintiff and counterdefendant Digital Envoy, Inc. (“Digital Envoy”) has identified the

10 documents attached as Exhibits P, R and S to the Supplemental Kramer Declaration as

11 “Confidential” and “Highly Confidential – Attorneys’ Eyes Only” pursuant to the Protective

12 Order entered in this matter on August 23, 2004.

13 Exhibit Q to the Supplemental Kramer Declaration is a document produced by third party

14 Advertising.com, Inc. in response to a subpoena issued by Google Inc. Advertising.com has

15 identified the document as “Highly Confidential – Attorneys’ Eyes Only” pursuant to the

16 Protective Order.

17 Without concurring in Digital Envoy or Advertising.com’s views, in light of their

18 designations, Google requests an order permitting it to file Exhibits P, Q, R and S under seal.

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20 Dated: March 16, 2005 WILSON SONSINI GOODRICH & ROSATI

Professional Corporation
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23 By: /s/ David H. Kramer

David H. Kramer
24
Attorneys for Defendant / Counterclaimant
25 GOOGLE INC.
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-1-
MISCELLANEOUS ADMINISTRATIVE REQUEST
TO FILE DOCUMENTS UNDER SEAL
CASE NO.: C04-01497 RS